Low-Income Housing Tax Credit Updates
AHTCC Provides Housing Credit Recommendations for Federal COVID-19 Response
Given the significant impact of the current COVID-19 crisis on the ability develop to build and preserve affordable housing, the AHTCC and our partners at the ACTION Campaign have provided recommendations to Congress that will help to mitigate negative effects and allow us to continue to build sorely needed homes for low-income households by providing accommodations for the Low-Income Housing Tax Credit (Housing Credit). For additional information, please see our blog post.
The AHTCC will continue to advocate for policies to strengthen our affordable housing delivery system at every opportunity. Beyond our intial recommendations, we will also advocate for additional resources and flexibilities for affordable housing as part of any future economic recovery package.
National Emergency Declaration May Provide Housing Credit Flexibility
A post from Novogradac & Co. explains that a Federal Emergency Management Agency (FEMA) fact sheet on the President’s national emergency declaration, along with previous IRS guidance, may allow some flexibility for Housing Credit properties seeking or already receiving carryover allocations. Specifically, Housing Credit properties may be able to receive additional time to meet the 10 percent test and allocating agencies may be able to grant placed-in-service extensions for properties already receiving carryover allocations. FEMA may provide additional clarifying information. Novogradac & Co. will update the post with additional information as it becomes available.
U.S. Department of Housing and Urban Development Updates
HUD Provides Guidance on COVID-19
The Department of Housing and Urban Development (HUD) has issued a question and answer document for Office of Multifamily Housing Stakeholders, including tenants, property owners, lenders, and other participants in Federal Housing Administration and HUD programs. The document provides links to additional information, including Multifamily emergency/disaster guidance, the Center for Disease Control and Prevention’s COVID-19 website, and the Health Resources and Services Administration’s health center database. See a summary of the document from Nixon Peabody here.
REAC Inspections Suspended
In light of the national emergency, the Real Estate Assessment Center, responsible for the inspection of HUD-assisted housing, has announced they will suspend inspections except where there is a an exigent circumstance or threat to life or property. A letter with more information from HUD leadership to Executive Directors, Tribal Leaders, and multifamily property owners can be found here.
Federal Relief Packages in Response to the COVID-19 Crisis
- Initial Emergency Funding Package: On March 6, President Trump approved an initial $8.3 billion emergency coronavirus package, providing funding for vaccine development and state and local health budgets.
- National Emergency Declartion: On March 13, President Trump declared the pandemic a national emergency, adding $50 billion in government funding to address the needs of the country.
- Families First Coronavirus Response Act: On March 19, President Trump signed a second relief package to provide funding for free coronavirus testing, emergency paid sick leave, paid family medical leave, unemployment insurance, food assistance, and other health provisions.
- Coronavirus Aid, Relief and Economic Security (CARES) Act: On March 27, President Trump signed a third relief package (see section-by-section bill summary, bill text, FAQ document), providing $2 trillion to combat the spread of the virus, deepen the safety net for impacted households, and support impacted business. For additional information, please see our blog post about the the components of the bill.
- Potential for Fourth COVID-19 Relief Package: Given the progression of the crisis and the economic fallout, a fourth and potentially other follow-up relief and recovery packages are possible.
Additional COVID-19 Response Resources
- Novogradac & Co. Resource Page: Federal legislation, congressional correspondence, and guidance; state housing finance agency policies and announcements; HUD guidance
- National Council of State Housing Agencies (NCSHA) Resource Page: Guidance from state housing finance agencies, the White House, and federal agencies, including HUD
- Enterprise Community Partners blog post: Local efforts to protect tenants, with a focus on eviction
If you have any suggestions for additional resources, please contact Megan John.